There are <insert number of
defendants> defendants on trial here. Although the defendants are being
tried together, you must consider the case against each separately. That is,
your findings in one case do not in themselves establish a basis for similar
findings in the other case[s]. Each defendant is to be considered as if
(he/she) were on trial alone for the offense or offenses for which (he/she)
stands charged. You will be required, therefore, to render a verdict upon each
defendant separately. The charges against each defendant are contained in
different counts. Each count charges a separate crime joined for the
convenience of the trial in one information. You must consider each count
separately and decide whether or not the state has proved each of the elements
of that crime beyond a reasonable doubt.

I remind you that during the course of
the trial certain evidence of <describe evidence> was admitted for you to
consider in the case of <insert name of defendant>, but you were
instructed not to consider this particular evidence in connection with the
charges against the other defendant[s]. Your verdict for each defendant must be
based solely on the evidence that was admitted for your consideration with
respect to that particular defendant. Where evidence was admitted with respect
to one defendant and not the other[s], you must consider it only with regard to
the appropriate defendant and disregard it as to the other[s]. Remember that
you will be required to return a separate verdict for each count.